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ASC QUALITY REPORTING Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. TODAY’S PRESENTER Paul Cadorette CPC, CPC-H, CPC-P, COSC, CASC Director of Education – [email protected] Paul has achieved his core credentials in Physician, Hospital, and Payor classifications from the American Academy of Professional Coders along with specialty credentials certifying his expertise in Orthopedic and ASC coding. Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Use of this handout is for informational purposes only – Confirm Carrier/Corporate policies before billing any services Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. October 1, 2012: ASC’s will be required to report on 5 quality measures Additional measures to be added in 2013 and 2014 Failure to report will result in 2% payment reduction for Medicare claims submitted in 2014 Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Benchmark • Minimum requirement 50% of relevant claims where Medicare is the primary payer - (2012 & 2013) • Threshold will be increased in future years • Currently, payment is for reporting • Payment for performance may be considered at a later date October 1 – December 31, 2012: • ASCs will be considered successful reporters and not face future financial penalties if 50 percent of their Medicare claims contain quality data codes. (This percentage may increase in future years.) In addition, ASCs should include the G-codes only on claims where Medicare is the primary payer January 1, 2013: • ASCs should begin placing the G-codes on claims where Medicare is either the primary or secondary payer Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Medicare Secondary Payer • While the change request for the carriers was released making the codes available for use April 1, 2012, CMS releases a tape for the private insurers once per year only. • CMS will release an updated tape in October/November of 2012 that will be active beginning January 1, 2013. • • ASC quality reporting G-codes are effective April 1, 2012 for Medicare carriers Private insurers will not have this information for use until January 1, 2013. • Private insurers will reject claims with the G-codes. Therefore, you should use these codes only for Medicare paid claims where Medicare is the primary payer. Where there is a secondary payer, the cross-over contractor should be handling the removal of the codes before forwarding, but CMS will be monitoring the situation. Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Use of Fall/Burn Measures • Admission: completion of registration upon entry into the facility • Discharge: occurs when the patient leaves the confines of the ASC • Patient fall in the parking lot (not reported) • Coffee spilled on patient causing burn (reported) • Patient is discharged from ASC and is immediately taken to hospital in private vehicle/car (reported) Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Reporting IV Antibiotic Timing • On time antibiotic infusion: initiated within one hour prior to the time of the initial surgical incision or the beginning of the procedure, or two hours prior if vancomycin or fluoroquinolones are administered The following antibiotics are considered prophylaxis for surgical site infections • Ampicillin/sulbactam, Aztreonam, Cefazolin, Cefmetazole, Cefotetan, Cefoxitin, Cefuroxime, Ciprofloxacin, Clindamycin, Ertapenem, Erythromycin, Gatifloxacin, Gentamicin, Levofloxacin, Metronidazole, Moxifloxacin, Neomycin and Vancomycin Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Frequently Asked Questions • Nurses routinely document what happened, not what didn't happen. If there's a patient burn, it's documented; if not, nothing is mentioned in the chart. In order to use the QDC codes, is this documentation required? • Documentation of non-events is not required. However, if your coding department is requiring such documentation, you may develop a tool that allows you to document the information Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Where are the G Codes reported on the claim form? • Quality-data codes (QDC) must be entered on the Form CMS-1500 and have an associated charge in order to be accepted into the CMS warehouse. These codes will populate Fields 24D and 24F on the Form CMS-1500. • The submitted charge field cannot be blank. • The line-item charge should be the numeral "0" (zero). Please note that dollar signs ($) or decimal points are not accepted. • If a system does not allow a zero line-item charge, a nominal amount can be substituted; the beneficiary is not liable for this nominal amount. • Entire claims with a zero charge will be rejected. The total charge for the claim cannot be zero. • When a zero charge or a nominal amount is submitted to the carrier or contractor, payment for the amount included in the ASC QDC line is denied and tracked. Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Where are the G Codes reported on the claim form? 211.3 45385 1200 00 G8907 0 G8918 0 211.3 E870.4 998.2 E849.7 45385 G8909 G8911 G8913 G8914 G8918 Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. These answers are based on guidance issued by CMS for the Physician Quality Reporting System (PQRS) program. While we anticipate that the agency will apply similar guidance to the ASC Quality Reporting Program (QRP), CMS could apply different standards. These FAQs will be updated when final guidance is issued by CMS. Will my ASC receive a Remittance Advice (RA) associated with a claim that contains a G-code line-item? • ASCs will receive an RA for a claim on which the G-code is reported. The RA will include a standard remark code (N365) and a message confirming that the G-code passed into the National Claims History (NCH) file. N365 - “This procedure code is not payable. It is for reporting/information purposes only.” The N365 remark code does not indicate whether the G-code is accurate for that claim or for the measure being reported.* • ASCs should keep track of all cases that they report using a G-code so that they can verify the G-codes that their ASC reported against the RA notice sent by their Medicare Administrative Contractor (MAC). Each Gcode line-item will be listed with the N365 denial remark code. • ASCs should note that the submission of a non-zero charge amount for G-codes may complicate secondary payers’ processing of the claims. ASCs are not allowed to collect any monies from beneficiaries for charges submitted for the G-codes. We forgot to put the G-codes on a claim. Can we resubmit the claim with the proper G-codes attached? • Claims may not be resubmitted for the sole purpose of adding or correcting G-codes.* We submitted a claim that was denied, but the error has been corrected and we plan to resubmit the claim. Do we include the G-codes again? • If a denied claim is subsequently corrected through the appeals process involving the carrier/Medicare Administrative Contractors, G-codes should also be included on the resubmitted claim in accordance with the instructions in the measure specifications.* Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Non “G” Code Reporting July 1 – August 15, 2013: ASC’s will be required to report: • Whether they used a safe surgery checklist at any time between January 1, 2012, and December 31, 2012 • Starting Jan. 2013, SSCL must be used for the entire year No particular checklist is required. For a list of sample safe surgery checklists, visit ascassociation.org/QualityReporting • The total Surgical Care Volume for selected groups of procedures • In 2014, one additional measure will be added to the list of quality reporting measures, Influenza Vaccination Coverage Among Health Care Personnel. This measure assesses the percentage of health care personnel who have been immunized for influenza during the flu season (October 1, 2014 – March 31, 2015) These measures are not patient-specific. They apply to the general operation of the ASC. Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. http://www.who.int/patientsafety/safesurgery/en/ Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. http://www.aorn.org/uploadedimages/Images/Images/comprehensive_surgical_checklist_RGB961.jpg Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. http://www.asge.org/WorkArea/showcontent.aspx?id=14262 Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Frequently Asked Questions • Does the Safe Surgery Checklist need to be a paper document or can it be a process? Can there be just a checkbox that states safe surgery checklist completed? • The CMS ASC Quality Reporting Program Quality Measures Specifications Manual on page 19 states: • The use of a Safe Surgery Checklist for surgical procedures that includes safe surgery practices during each of the three critical perioperative periods: the period prior to the administration of anesthesia, the period prior to skin incision, and the period of closure of incision and prior to the patient leaving the operating room. • CMS does not state any requirement for documentation at the patient level. This is the decision of the facility. Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. ASCs will be required to report their total surgical volume for certain specified procedures performed Jan.1 - Dec. 31, 2012 for all patients (Medicare and non-Medicare) in 1 of the 9 categories listed below Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Reporting Outcome Measures • 5 Quality measures (G8907-G8918) are reported on Medicare Claim Forms (CMS-1500) Structural Measures – www.qualitynet.org • Safe Surgery Checklist Use • ASC Volume of Selected Procedures • Influenza Vaccination Coverage Among Health Care Workers www.cdc.gov/nhsn/index.html - (HCP definitions pending) • Staff on facility payroll • Licensed practitioners (Physicians, APN’s and PA’s) • Students and volunteers • Still to be determined – Vendors Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. How to Prepare Your ASC • Communicate the upcoming changes to your staff (clinical and business) and physicians • How will data collection be performed and processed by the billing department • Designate a responsible staff member • Facility will need a Quality Net administrator • Establishing and maintaining account • Reviewing and communicating updates/changes (every 6 months) • Review specifications of measures • Staff (clinical and business) training • Begin the process of collecting data Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Quality Net Reporting • ASCs will be required to designate an individual to serve as the Center’s QualityNet administrator (no later than Aug. 15, 2013)• ASCs should allow two weeks to complete the process of registering a QualityNet administrator with CMS • Because these accounts are deactivated after 120 days of inactivity, it is recommended that ASCs wait until mid March 2013 to register Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. REVIEW OF LESIONS INTEGUMENTARY CODING Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Adjacent Tissue Transfer 4cm Primary Defect Primary defect: 2cm x 2cm = 4sq cm Secondary defect: 4cm x 2cm = 8sq cm Total Size: 4sq cm + 8sq cm = 12sq cm 2cm 2cm Add the sizes of both secondary defects to the primary defect to determine the proper CPT code 2cm Secondary defect Advancement flaps Secondary defect Primary defect Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Undermining alone of adjacent tissues to achieve closure, without additional incisions does not constitute adjacent tissue transfer; see complex repair codes 13100-13160 Wide excision of scalp angiosarcoma with adjacent tissue transfer An ellipse was fashioned around the previous biopsy site which measured 5cm by 3cm. Dissection was made down to temporalis fascia which was left undisturbed and the mass was submitted to pathology. The edges were widely undermined, advanced toward each other and reapproximated. Attention was then turned to the foot where the lesion on the lateral aspect of the dorsum was excised with the #15 blade. The margins were undermined and flaps were advanced. Closure was carried out with 5-0 Vicryl and interrupted 6-0 nylon vertical mattress sutures. Advancement flaps Undermining Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Documentation Do not add the total length and then multiply by the largest width 7x4 and 7x5 14 x 5 = 70sq cm or 14 x 9 = 126sq cm 2x2 and 2x3 = 10sq cm 4x3 = 12sq cm or 4x5 = 20sq cm 14301 – Adjacent tissue transfer or rearrangement, any area; defect 30.1 to 60.0sq cm 14302 – each additional 30.0 sq cm or part thereof Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. Adjacent Tissue Transfer Question: When you have 2 lesions from the same anatomical area (trunk) and separate adjacent tissue transfer procedures are performed for each defect how is this reported? Answer: You would report one CPT code for each tissue transfer procedure as long as the margins were separate and not contiguous. Do not add the sizes together and report one CPT code (Loss of Revenue) CPT ASSISTANT JUL: 00 Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Intermediate Repair (Closure) • The "deeper layers of subcutaneous tissue and superficial (nonmuscle) fascia" referred to in the CPT definition of intermediate repair refers to subcutaneous tissue that is deeper than the dermis rather than to the deep subcutaneous tissue. • In summary, wounds that require closure of subcutaneous tissue or more than one layer of tissue beneath the dermis should be coded as intermediate repairs, unless the criteria for a complex closure are met. CPT ASSISTANT AUG. 06 Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. Tumor vs. Lesion Coding • DIGITAL TUMORS – (fingers/toes) – subfascial is defined as those tumors involving the tendons, tendon sheaths or joints of the digit. Tumors which simply abut but do not breach the tendon, tendon sheath, or joint capsule are considered subcutaneous soft tissue tumors Do not use tumor codes when a CPT code exists for “Excision of lesion of tendon sheath or joint capsule (cyst or ganglion)” • Hands/Fingers and Foot/toes • Less than 1.5cm - 1.5cm or greater Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Tumor vs. Lesion Coding • Question: What is the appropriate code to report for excision of epidermal or pilar cyst? • Answer: Excision of epidermal or pilar cysts are properly coded with the integumentary excision codes, together with an intermediate repair code “when indicated”. Because they originate from the dermis or adnexal structures, they are not soft tissue tumors, even though they may protrude into the subcutaneous tissue. JUL. 10 CPT Assistant Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved. Tumor Code Guidelines • Additionally report “appreciable” vessel exploration and/or neuroplasty (APPRECIABLE – sufficient to be easily seen, measured or noticed) • Tumor size – greatest diameter + most narrow margins (same as lesion coding) • Simple and Intermediate repairs are included in the tumor excision codes • Complex repair, flaps and grafts are additionally reported Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. Repair/Closure Guidelines • Simple repair is included in the lesion excision • Add the lengths of repairs….. • That are in the same classification (simple/int/complex) • That are grouped in the same CPT code descriptor (Intermediate repair of 5cm scalp wound and 12cm trunk wound – Report 17cm wound closure) • List repairs by order of complexity • Complex (1st), Intermediate (2nd), Simple (3rd) Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. Repair/Closure Guidelines • Debridement is only reported when “appreciable amounts of contaminated tissue are removed or when debridement is the only procedure performed without closure” • Repair of injuries to tendons, nerves or blood vessels are reported with a CPT code from the anatomical section – repair then becomes inclusive unless complex CPT MANUAL INSTRUCTIONS Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. Surgical Preparation • Codes 15002-15005 “describe the services related to preparing a clean and viable wound surface” • Application of grafts include simple debridement of granulation tissue or recent avulsions (tangential – lightly touched, of no consequence) • Complex repair, adjacent tissue transfer, flaps, grafts, skin replacements, and skin substitutes are reported separately Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. Surgical Preparation • Example 1 • Example 2 Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. Graft Preparation • Graft preparation includes simple debridement of granulation tissue or recent avulsion • “Excision” of open wound, burn eschar, or scar • “Incisional” release of scar contracture • Using a sharp #15 scalpel blade and forceps, an incision was made and the wound was ellipsed including a margin of normal tissue that measured approx. 9 cm in length and 3 cm wide. Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. “or part thereof” • FTSG trunk - 6cm x 7cm = 42sq cm • Report 15200 for the first 20sq cm • Report 15201 for an additional 20sq cm • Report 15201 for the last 2sq cm since it is part of an additional 20sq cm 20 + 20 + 2 = 42 Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. Multiple Skin Grafts Question: A 3sq cm FTSG was placed on the cheek, chin and a finger. Since this was 3 separate anatomical areas would 15240 be reported 3 times? Answer: No, since cheek, chin and fingers are all identified by the same full thickness graft code and the total area covered was 9sq cm CPT code 15240 would only be reported one time CPT ASSISTANT NOV: 00 Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. Modifier Usage • Do not use a modifier if the definition of a CPT code is used for multiple body parts CPT ASSISTANT MAY: 03 FOR EXAMPLE • Excision of lesion trunk, arms, legs • Excision of lesion face, ear, eyelid, nose, lip • Modifier 59 may be need when multiple lesions are excised (Specific carrier guidelines) Current Procedural Terminology © 2011 American Medical Association. All Rights Reserved. CEU’s • Go to www.mdstrategies.com and select the TRAINING tab. • Login using your email address and password. If you have forgotten or did not receive your password, use the “Forgot Password” link. Attendance CEU • Complete the “Post Webinar Exam” for the Attendance CEU Supplemental CEU • Complete the “Supplemental CEU Exam” for additional CEU credit • If you have any questions or problems, please email [email protected]. Current Procedural Terminology © 2012 American Medical Association. All Rights Reserved.